Parra, Jose

Applicant's attorneys (Shandler & Associates) sought penalties, interest, sanctions, and attorney's fees seventeen years after a 2001 OACR for defendant's failure to timely pay $2,687.50 in section 5710 deposition fees, which defendant paid (plus a self-imposed 10% penalty) within three weeks of the 2018 demand. The WCJ found all claims barred by laches and ordered reimbursement to defendant of payments exceeding $2,687.50. The Appeals Board, granting reconsideration on its own motion to correct a clerical error in a prior decision, held that defendant failed to establish the laches defense (notably lacking clean hands), but that the section 5814 penalty claim was time-barred by the two-year statute under section 5814(g). The Board awarded section 5800 interest on the 5710 fees from the OACR date to payment, ruled the self-imposed penalty belongs to applicant (not his attorneys), denied 5814.5 fees and 5813 sanctions, and rescinded the reimbursement order.